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Women’s Education in Colonial India: The role of women’s movement, transnational actors and the local pioneers

Published onJul 13, 2023
Women’s Education in Colonial India: The role of women’s movement, transnational actors and the local pioneers
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Women’s Education in Colonial India: The Role of women’s movement, transnational actors and local pioneers

The role of the women’s movement in India in claiming voting, citizenship and legal rights for women has been well documented (see for example Forbes 1979; Forbes 1981; Jayawardena 1986; Ramusack 1989; Sinha 2000; Jayal 2013; Mukherjee 2018; Devenish 2019; ). However, the women’s movement also played a crucial role towards the education of girls and women. Studies ( Southard 1984, 1993, 1995; Chakravarti 1998; Kosambi 2000; Felton 2003; Bagchi 2009 ) have well documented the contribution of individual women activists as well as the organised women’s movement at the provincial level towards the education of girls and women. In continuation with these scholarly works, this article intends to shed light on the activities of non-Indian and Indian woman activists who contributed towards Indian women’s education. Moreover, this article aims to hint towards the role of global connections and local activism in the efforts for the education of Indian girls and women. I have chosen Annie Besant and Margaret Cousins as transnational actors and Abala Bose and Kulsum Sayani as local pioneers. Besant and Margaret Cousins have been extensively studied for their involvement in the freedom struggle ( Sri Prakasa 1962; Aiyar 1963; Kumar 1981; Bakshi 1990; Geetha & Rajadurai 1995; Chaganti 1996; Chandra 2001) and feminism (Ramusack 1993; Candy 1996; Atwal 2022) respectively, but their contribution to the education of Indian girls and women is an underexplored area of study. The same is true of Abala Bose and Kulsum Sayani who championed the cause of education of adult women under seclusion but have not received much scholarly attention from the historians of the women’s movement and the historians of education. This article, however, does not claim to be an exhaustive study of the educational activism of these historical actors. Through a preliminary analysis of the educational works by these transnational and local actors, this article raises certain questions as a starting point for further research.

Annie Besant (1847-1933)1

Annie Besant in 1922

Source: https://www.varanasi.org.in/wp-content/uploads/img/annie-besant-

Annie Besant came to India in 1893 as a leader of the Theosophical Society2. Besant became popular in India for her involvement in the Indian freedom struggle through the Home Rule Movement and as the president of the Indian National Congress3. However, for the first twenty years of her stay in India (1893-1913), she channelised her energy towards the religious education movement for upper caste Hindu boys. In 1904, she shifted her attention to the religious education of upper-caste Hindu girls, when she published a pamphlet entitled Education of Indian Girls. For Besant, the objective of the education of upper-caste Hindu girls was to train girls for their future roles as Hindu wives and Hindu mothers. Since Besant believed that the position of Indian girls was to be within the confines of the four walls of the home, she devised a simple education of girls with training in homely and religious duties at the core of her programme. She was against the Western education of Indian girls because it would “unsex” them (Forbes 2012: 44). She argued that Indian girls’ life was “family life”, and asked why must they “waste the years during which they should be educated to play their part well in the family” on getting an education “suited for western life? ” (Besant 1917: 113-114). While in England Besant vehemently advocated for women’s rights and their higher education4, in India she “took an elitist attitude” (Jayawardena 1995: 132) and romanticised Indian patriarchy, thus overlooking the hardships imposed on Indian women. She criticised the higher education of girls which would prepare them “for the learned professions” as the general Hindu conception of a woman’s place in national life was “the mother and the wife” and not the “rival and competitor of man in all forms of outside and public employment, as woman, under different economic conditions, is coming to be, more and more, in the West” (Besant 1904: 2).

In 1904, following the publication of her pamphlet on the Education of Indian Girls, Besant established a school for the education of upper-caste Hindu girls in the city of Benares, named Central Hindu Girls’ School. This school was opened with active support from Francisca Arundale, an English Theosophist who came to India in 1903. Through this school, Besant strived to concretise her ideas on the education of Indian girls. The school was only open to girls of the higher castes. The reason put forth by Besant was that these girls had “refined home training” and therefore “careful parents can send their little daughter without any fear that they will catch up undesirable words or habits” (Besant 1905: 130). The school was transnational and cross-cultural in terms of the teaching staff: Francisca Arundale (an English theosophist and principal of the school), Miss Palmer (an American theosophist), three Hindu and four Bengali teachers who were wives of the Hindu theosophists. We do not have any testimony of the girls who attended the school. However, it is interesting to imagine the challenges faced by the girls and the new lessons learnt by them on account of their proximity to culturally diverse women teachers.

The school was run mainly by donations and periodical subscriptions from India, Europe and America. The branches of the Theosophical Society in these places played an important role in the collection of funds. However, these subscriptions were meagre and therefore not sufficient to run the school for a long time. This is clear from the following appeal by the secretary of the school, Annie J. Wilson:

We had hoped to make [the school] self-supporting by the endowments but in the beginning of the financial year the treasurer pointed out that the expenses exceeded the income and by permission of the board of trustees we had to take some Rs 2000 from our reserve fund. […] Although the parents are beginning to appreciate education for their girls, as is shown by the more regular attendance, only a comparatively small portion show themselves willing to pay anything for it; needless to say, the school will go on as long as it can, but we must most earnestly beg you to note that, unless practical help is given, this useful activity will be maimed if not extinguished. (Wilson 1911: 14)

Purdah (seclusion) was very strictly followed by the school. It was highlighted as one of the special features of the school in its prospectus. The school had closed omnibuses pulled by horses or by bullock-carts in which “the little ones can be safely packed into the carts by the ladies in a way which is not possible on a public road” (Report CHGS 1907: 5).

Jessie Duncan Westbrooke, a women suffragette from England, visited Besant’s school in 1910. She was very critical of the Purdah norms at the school. She argued that the closed carriages were akin to a “cage” and contrasted their education with those of “coolie” women in the sense that “at least the education given by contact with the real outside world” was available to the lower caste “coolie” women and questioned, “[h]ow at the present day is the illiterate Indian woman of the middle or upper classes to get any education or educative experience at all?” (Westbrooke 1910: 513).

The curriculum at the school laid great emphasis on teaching religious and moral stories of Sita, Savitri, Damayanti etc., from mythological texts to ensure the internalisation of high ideals of virtuous and spiritual women of the East. For Besant, such education, as advocated by her and practised in her school, would make the Indian girl “fit to be the ‘Lakshmi [goddess of fortune] of the house’”, thus making the Indian home “the centre of spirituality, the strength of the national religious life” (Besant 1917: 115).

It can’t be denied that Besant made efforts towards formal schooling of girls in the orthodox city of Benares5. Nonetheless, “she attempted to liberate neither their ‘caged body’ nor their ‘caged mind’ from the shackles of Brahmanical patriarchy” (Singh 2018: 625). It is a paradox that Besant, “who herself revolted against the Victorian patriarchy, the Victorian ideal of the good wife and mother and her religion, sought in India to make the religious, docile, chaste, ideal wife and ideal mother through religious and home education” (Singh 2018: 625). As Nethercot, Besant’s biographer, rightly argues, “Besant knew how to wear sandals in India and shoes in the rest of the world” (Nethercot 1963: 469).”

Despite her narrow ideals of education for Hindu girls, Besant was admired by the leaders of the women’s movement in India and was considered a source of inspiration for their activism. In the words of Mutthulakshmi Reddi:

The example of Dr Besant and her organised body of devoted women co-workers has been a source of inspiration to us Indian women. May we now imbued [sic] with the same spirit that has actuated those noble hand of highminded workers, who even though, born and bred up in a foreign soil, have felt acutely for the sufferings of their Indian sisters and have laboured for their uplift, rise to the occasion, give up all our selfishness and our petty quarrels and work for the good of all without distinctions of caste or creed or race. (Reddi undated speech: 197)

Margaret Cousins (1879-1954)

Margaret Cousins, 1932

Source: https://en.wikipedia.org/wiki/Margaret_Cousins

Margaret Cousins was an Irish feminist and devout Theosophist. She came to India in 1915 and was appointed as a teacher of English, Domestic Science and Handicrafts in the High School at Madanapalle (two hundred miles from Madras) run by the Theosophical Society (Candy 1996: 104). In June 1916, Cousins was nominated as a member of the first senate of the Indian Women’s University at Pune established by Professor D.K. Karve. During her visit to Pune Cousins was astounded to meet English-educated elite Indian women. She recalls in her joint autobiography with her husband:

I was delighted to get to know a group of upstanding, intelligent women, who had been helped to social and mental freedom by their saintly Guru, and had gathered around him to help others to the larger life. I was envious of them and envious of the good is a stimulus to good action. (Cousins & Cousins 1950: 278)

This meeting with “upstanding intelligent women” made Cousins optimistic about her future reforms and public life with the support of these women. She wrote to Hanna Skeffington, her friend and partner in her female suffragette work in London, that “[m]y work for the women is opening out finely and is giving me great satisfaction. Local events are playing into my hands” (quoted from Candy 1996: 126).

Later in 1916, Cousins founded the Abala Abhivardini Samaj (Weaker Sex Improvement Society). With support from another theosophist Dorothy Jinarajadasa, the Samaj was expanded into the Women’s Indian Association (WIA) in 1917 with 70 members. The education of Indian girls was one of the chief concerns of Cousins. The WIA under the leadership of Margaret Cousins resolved “[t]o secure for every girl and boy the right of Education through schemes of Compulsory Primary Education, including the teaching of religion” (Report WIA 1930: 1).

Cousins played an important role in penning down the memorandum, submitted in 1917 to the reforms committee headed by Montagu and Chelmsford, regarding votes for women. A significant portion of this memorandum included the appeal for educational reforms for girls. This was a subject which was out of the purview of the committee, yet Cousins included it, as she “felt that improving the literacy rates and access to education among Indian women was the first step to emancipation” (Candy 1996: 141). An excerpt of the memorandum dealing with girls’ education is outlined below:

In order to fit ourselves and our children for future public responsibilities arising out of the foregoing considerations, it is absolutely essential that our educational system should be reformed. At present only one girl out of every hundred, and only thirteen boys out of every hundred, are educated. We bring the urgent necessity for immediate action in educational matters before you now because the granting of facilities for education is a section of Indian Administration definitely under the control of the Imperial Legislative Council and the Government of India, and it must be made as far as possible a uniform policy throughout all British India. We therefore ask (1) that the Government shall make a pronouncement in favour of Compulsory and Free Primary Education, and immediately set to work to bring this into being area by area, as is being done in several of the Indian States. (2) We ask that during the time elapsing before the completion of this reform, the Government shall immediately devote as much attention to the education of girls as it is now giving to boys, and provide an equal number of school facilities for them, and thus remove the unwise differentiation which provides facilities for ten times as many boys as girls, a policy which defeats its own ends, as the uneducated wives of these boys later hold back their progress. In order to supply teachers for this wide spread of education, we ask the Government to provide a largely increased number of Training Colleges for Indian Women Teachers and also to establish a number of Widows’ Homes for this purpose, supplemented by the grant of scholarships to widows and those anxious to be trained as teachers. Several travelling scholarships should also be made to assist Associations which are now so widely attempting to continue the education of married women outside ordinary school hours and curricula. (Cousins & Cousins 1950: 111-12)

Apart from vocal appeals to the government, efforts were made by Cousins through her activism to make provision for free and compulsory education for girls in Madras Presidency. She headed the deputation which waited on the education minister of Madras “to urge the inclusion of girls in the Compulsory Primary Education schemes that are being operated in over sixty villages of their district” (Report WIA 1930: 3). Margaret Cousins along with other members of the WIA made special surveys of girls’ education in the towns of Madras to carry out agitation for educational reform. The headquarter of the WIA communicated with all Municipal Councils and demanded that girls should have an equal share in the money and facilities connected with their compulsory schemes. The association tried to persuade governments to make the inclusion of girls a condition of receiving government cooperation and grants for compulsory education. The association also ensured that branches of the association had their representatives on all School Attendance Committees and on the District Educational Councils (Report WIA 1930: 4). By the efforts of Cousins, girls were finally included, in 1930, in the compulsory elementary education scheme of the Municipal Corporation of Madras.

In 1926, concerned about issues in women’s education in India, Cousins wrote an appeal to members of women’s associations across the country, calling on them to meet and outline their thoughts regarding educational reform and to select a representative to attend a special conference in Poona. This eventually resulted in the first session of the All India Women’s Conference in 1927 at Poona. Due to the focus on women’s education, AIWC was initially christened the All India Women’s Conference on Educational Reform. In 1929, it was decided to widen the scope of the conference to social issues and hence the term ‘Educational Reform’ was dropped.

Through the AIWC, efforts of Cousins along with Rajkumari Amrit Kaur, Kamladevi Chattopadhyay, and Hansa Mehta among others led to the formation of All India Women’s Education Fund which eventually gave birth to the Lady Irwin College for women in 1932. Moreover, Cousins led great emphasis on the physical education of girls. She ensured that physical education was a necessary part of the curriculum in all the girls’ schools run by the Theosophical Society and also at Lady Irwin College.

Despite the little and slow successes achieved, Cousins was not satisfied with the government’s expenditure on girls’ education. In her Presidential address at the annual meeting of the AIWC for the year 1936, Cousins lamented that “Even within the meagre amount available for education here we women are not getting a fair deal. Fourteen times more money is spent on boy’s education than on girls” (Report AIWC 1936: 27). She suggested that two-thirds of the government’s grant to each Province, under the Government of India Act 1935, be immediately allocated for spreading elementary education as “the safest and most valuable investment for the future” (Report AIWC 1936: 27).

The education of Indian girls was one of the chief concerns of Cousins. Her advocacy for free and compulsory education as a right of girls on equal footing to that of boys was a radical move of the time. In contrast to Besant, Margaret Cousins had more progressive views regarding the education of women and girls. Though Cousins also romanticised the idea of spirituality of Eastern women and that education is necessary for women to make them better wives and mothers. Nonetheless, unlike Besant, she was not only concerned with the education of women of upper castes but also with those belonging to the lowest strata in the caste hierarchy. As Candy (1996) rightly argues, the motivating factor for Cousins's activism for women’s education and voting rights “was Cousins’s sense of isolation and desperate need to feel connected to a bigger world which compelled her efforts to forge a cause in which to invest herself” (p. 105).

Abala Bose (1865-1951)

Abala Bose

Source: https://en.wikipedia.org/wiki/Abala_Bose

Abala Bose was the daughter of Durga Mohan Das, the leader of Brahmo Samaj6 and an advocate of the education of girls on an equal footing to that of boys. Belonging to a Brahmo family, she received a liberal education at Bethune College in Kolkata. Ironically, Bose is not known for her educational work or her activism. She is mainly remembered as the wife of Jagdish Chandra Bose, a famous physicist and scientist. However, a peek into the history of women’s education in Bengal reveals that she played a very significant role in the education of girls and Purdah women in villages of Bengal. Bose had a very radical view of women’s education, which was much ahead of her time. According to her:

women should have a deeper and extended education, not because we may make better matches for our girls … not even that the services of the daughter-in-law may be more valuable in the home of her adoption, but because woman like man is first of all a mind, and only in the second place physical and a body. (quoted from Ray 1990: 36)

Abala Bose got the opportunity to travel to Europe in 1896 along with her scientist husband. This trip to Europe broadened her horizons. She observed how girls’ schools were run there, particularly the Montessori system of education. Margaret Cousins reminisces in The Awakening of Asian Womanhood that Bose once told her that “nothing broadens one’s outlook so much as meeting representative men and women of different nationalities and yet finding humanity much the same despite its surface differences” (Cousins 1922: 130). On her return to India, she was appointed as the secretary of the Brahmo Balika Shikshalaya (Brahmo Girls’ School) in Calcutta and served this post for the next 26 years.

In 1915, Abala Bose established Nari Shiksha Samiti (Women’s Education Association). The Samiti aimed to establish primary schools, prepare suitable textbooks, and open maternity and child welfare centres. It worked to start a chain of Purdah Schools which aimed to reach out to women in Purdah. As Frieda Hauswirth puts it:

She [Abala Bose] knew that the mother-in-law behind the purdah is the most formidable obstacle to progress, and has power to keep all women under her within purdah, all girls away from school. Win her over, and half the battle is won, the younger generation is liberated. (Hauswirth 1932: 179)

Through the Samiti, Abala Bose established 88 primary schools in Calcutta, including the still-existing Muralidhar College and 14 adult education centres. In 1919, she established the Brahmo Girls’ School. She also dedicated a share of her property to the upkeep of the school (Hauswirth 1932: 180).

In 1925, Bose established the Vidya Sagar Bani Bhawan which provided both teacher training as well as education to widows. These women would then be employed by schools that came under the jurisdiction of the Nari Shiksha Samiti. Abala Bose was able, through her efforts, to secure donations from the government and philanthropists. In her report to Margaret Cousins, she noted:

Government sanction of a capital grant of Rs 4833 and a recurring annual grant of Rs 5260 having been received this year the industrial section of the Nari Shiksha Samiti, hitherto known as the Cottage Industries Department, was, with the help of generous donors, placed on a firm footing and named the Mahila Shilpa Bhawan. […] The thanks of the Samiti are due to the Government of Bengal for contributing Rs 6500 to the Samiti’s rural school, Rs 4100 to the Vidyasagar Bani Bhawan and Rs 8248 for the Mahila Shilpa Bhawan. (Cousins to Reddi 1928: 5)

It was not a small achievement. This could be gauged from the fact that Cousins wrote to Muthulakshmi Reddi stating that they should also make similar efforts to get government grants in the Madras presidency.

You will notice the very large amount given to the industrial home which is run on just the same lines as the Home of Service—indeed it has even less literary and cultural training, music is not allowed at all and there are in it only the vocational classes. The other home is almost entirely on the lines of Sister Subbalakshmi’s new home. They have onle [sic] 54 students in the Shilpa Bhawan and we have had 80 on pur [sic] rolls this year and during the time working have passed through our hands 380 students. We are asking for a similar annual recurring Grant of Rs 5000 for Home of Service. I think we were modest and asked Rs 300 per month: Madras should equal Bengal in Helping its adult women. (Cousins to Reddi 1928: 5)

The Vidyasagar Bani Bhawan was quite successful but due to scarcity of space, the admission of inmates had to be refused. This is clear from the report for the year 1928:

The Number of inmates in the Vidyasagar Bani Bhawan rose from 20 to 28 during the year which was practically the maximum that could be with considerable difficulty be accommodated in the house rented for the purpose. Of these five had been reading in the Training Department of the Brahmo Girls’ School, the rest being regular students of the literary section of the Bhawan teaching up to the Middle English Section of the Education Department. (Cousins to Reddi 1928: 5)

The foregoing discussion shows that Abala Bose tried her level best to secure education for girls, purdah women and widows. As a token of appreciation for her work, she was chosen the first president of the Bengal Women’s Education League, established in 1928. However, the history of women’s education has not given due credit to Bose who worked at the local level to ensure the education of the most neglected.

Kulsum Sayani (1900-1987)

Kulsum Sayani with her sons

Source: http://www.mpositive.in/wp-content/uploads/2018/01/KulsumSayaniMPOs04jan2018.jpg

Kulsum Sayani is another forgotten social activist and educator. Sayani pioneered the adult education programme in Bombay. She was part of the first National Planning Committee which was set up by the Congress government under the chairmanship of Jawaharlal Nehru in Bombay in 1938. In the questionnaire of the Planning Committee, there was a question on “How to educate Purdah Women?”. In response to this Sayani devised a home education scheme and started working among Muslim women with Rs 100 in her hand. She employed two teachers at Rs 20 per month and each teacher was allotted 25 students. Sayani herself started doing the rounds of Muslim areas to gather the required quota of 25 students per teacher. In a later interview, Sayani revealed:

The quota of 25 students per teacher could not be gathered in one individual group, hence the teachers had to go from building to building. It was an uphill task. The interest of the women students was difficult to sustain, so dogged perseverance and close personal contact was needed to make the scheme successful. […] I used to roam from house to house and lane to lane collecting women, persuading them to read and write. (Interview Part I 1970: 4)

The All India Women’s Conference and the Bombay City Social Education Committee came up with offers to run the scheme on a large scale. Inspired by her work, B. G. Kher, the Premier of Bombay, asked her to take over the 50 centres for Purdah women’s classes started by the Bombay City Social Education Committee and make them a success. Slowly and steadily the classes grew and reached 600 in numbers. Ten years later, in her letter to Rameshwari Nehru in 1948, Sayani expressed that “[t]he adult education work has increased 20 fold. We are aiming to make Bombay literate within ten years” (Sayani to Nehru 1948: 8).

Sayani travelled extensively to London, Paris, Geneva, Denmark, Baghdad, Cairo, Jerusalem and Karachi in the decade of the 1950s. During her visits, she studied the educational system of these countries which informed her adult education programme in India. To keep up the interest of the new literates, Sayani started editing and publishing a fortnightly journal called Rahber in Hindustani language and three scripts viz., Devanagari, Urdu and Gujarati. The journal was used in the classes of the Bombay City Social Education Committee. It published “a rich variety of useful reading matter for adults dealing with Indian culture, history, geography, general knowledge, village problems and news” (The Appeal 1948: 9).

Apart from adults, the journal was also very popular among schoolchildren. Copies of the journal were supplied free to about 500 primary schools in Bombay. The journal despite being successful faced a financial crunch. In 1948, an appeal for financial support to the journal read:

So far this work has been carried on as a devoted labour of love by Mrs Sayani at her own initiative and partly at her own expense. The Bombay Government has been giving, as a token of appreciation an annual grant of Rs 1500/- but this is obviously insufficient to meet the expenditure involved in bringing out the journal in three scripts. (The Appeal 1948: 9)

Sayani published the journal single-handedly for 20 years but lack of funds led to its closure in 1960. The journal was immensely popular and received notes of appreciation from several prominent leaders of the time including M. K. Gandhi, Jawaharlal Nehru, Rajendra Prasad and Morarji Desai. Hilla Rustomji Faridoonji in her letter to Sayani noted:

…My heartfelt congratulations on your great and solid work. It’s a wonderful paper & may you live long to increase its activities a hundred fold & may your noble example be followed by hundreds of others in every large town. What a place adult education would take if even half a dozen persons in every town would work on your lines. You are after my own heart as you are doing practical work without talking. (Faridoonji to Sayani 1945)

In 1970, the Times of India noted:

From 1939 when she (Kulsum Sayani) took charge of the Bombay City Social Education Committee five lakh adults have become literate through one of the five languages – Urdu, Hindi, Gujarati, Marathi and Telugu. Her days are a mad rush of dashing to schools to enthuse children into teaching adults and her nights are spent dreaming up new schemes of literacy. (Kulsum Sayani Papers)

Thus, Sayani pioneered the adult education programme in Bombay and left no stone unturned to bring adult purdah women within the purview of education. For her contribution, the Government of India honoured her with ‘Padma Shri’ in 1959. However, the history of education in India has yet to do justice to Sayani by undertaking a detailed analysis of her work.

Concluding remarks

The story of activism for Indian girls’ and women’s education is not confined to the actors discussed in this article. Several other well-known and lesser-known activists worked towards the cause of education for girls and women in India. Through this article, I show that the efforts for Indian women’s education were both global and local phenomena. It was global in the sense that transnational actors such as Besant and Cousins not only took initiatives towards girls’ education but also used their networks in India and abroad (i.e. through the Theosophical Society) to collect funds and support for the cause. Besant’s views towards girls’ education were quite conservative, nonetheless, her school provided the platform for Indian women teachers and girl students to get exposure to Western ideas through interaction with European and American women teachers. Another significant aspect which I highlight is that Cousins’ proactive role in the inclusion of girls in the compulsory elementary education scheme was probably informed by her Irish roots, where Compulsory Primary Education Act was enacted in 1890. This Act was the basis of the Primary Education Acts enacted by the Provinces in British India. Moreover, through the foundation of AIWC, Cousins created an all-India platform for Indian women to act and take up the cause of their less fortunate sisters. What needs to be explored further in the case of Besant and Cousins is how and in what ways they used their networks abroad, through the Theosophical Society or otherwise, in getting funds and support for female education in India.

The cases of Abala Bose and Kulsum Sayani discussed in the article show that their activism was partly informed by their foreign visits. These visits not only broadened their worldview but also imbued them with the knowledge of modern pedagogies which they tried to implement locally through their activism. The questions which need further exploration are: what were the specific educational experiences of Bose and Sayani during their foreign visits? How did they use these experiences in devising pedagogies for the education of girls and women? and lastly, did they form connections during these visits to foster the cause of women’s education in India?

These pioneers of adult education programmes in their respective provinces worked at the grassroots level and made it their life mission, but they have been consigned to oblivion. Through this article, I would like to point out that it is imperative to document the history of their activism and the national and transnational channels through which they gave shape to their ideas and efforts. The aspect of how local activism is interwoven with global dynamics in the educational arena of women’s movement needs further exploration, in general, and in these two cases of Abala Bose and Kulsum Sayani, in particular.

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